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TMI Blog2021 (3) TMI 3X X X X Extracts X X X X X X X X Extracts X X X X ..... bmitted during the course of assessment proceedings. 3. Both the Ld. A. O. and CIT(A)-5,Ahmedabad ought to have considered the other cash outflows also over and above the cash deposited into bank of Rs. 1,39,85,200/-before arriving at the difference of Rs. 83,67,590/-, when the month wise details of cash receipts and cash expenses were submitted to A.O. at the time of assessment proceedings and the same are on record. 4. The appellant craves leave to add, alter or delete any ground either before or in the course of hearing of the appeal. 2. Facts of the case are that Ld. A.O. selected assessee's case for limited scrutiny and notice u/s 143(2) and 142(1) r.w.s. 129 were issued. 3. That as per AIR Data information, assesse has made cash deposits of Rs. 2,79,70,400/- with Corporation Bank and as per CIT information the assesse has made cash deposits of Rs. 19,75,800/- with HDFC Bank aggregating to Rs. 2,99,46,200/-. Assessee asked to explain the source of the same with supporting documents. And in response to the notice, assesse stated that there are number of withdrawal of cash on various dates which was utilized for depositing into the Bank. But Ld. A.O. was not agree with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... remain confined only to the specific reasons/issues for which case has been picked up for scrutiny. Further, the scope of enquiry shall be restricted to the 'Limited Scrutiny' issues. c. These cases shall be completed expeditiously in a limited number of hearings. d. During the course of assessment proceedings in 'limited Scrutiny' cases, if it comes to the notice of the Assessing Officer that there is potential escapement of income exceeding Rs. five lakhs (for metro charges, the monetary limit shall be Rs. ten lakhs) requiring substantial verification on any other issue(s), then, the case may be taken up for 'Complete Scrutiny' with the approval of the Pr. CIT/CIT concerned. However, such an approval shall be accorded by the Pr. CIT/CIT in writing after being satisfied about merits of the issue(s) necessitating 'Complete Scrutiny' in that particular case. Such cases shall be monitored by the Range Head concerned. The procedure indicated at points (a), (b) and (c) above shall no longer remain binding in such cases. (For the present purpose, 'Metro charges' would mean Delhi, Mumbai, Chennai, Kolkata, Bengaluru, Hyderabad and Ahmedabad). ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... one case the Central Inspection Team of the CBDT was tasked with examination of assessment records on receipt of allegations of several irregularities. Amongst other irregularities, it was found that no reasons had been recorded for expanding the scope of limited scrutiny, no approval was taken from the PCIT for conversion of the limited scrutiny case to a complete scrutiny case and the order sheet was maintained very perfunctorily. This gave rise to a very strong suspicion of mala fide intentions. The Officer concerned has been placed under suspension. 9. Ld. A.O. issued notice u/s. 142(1) mentioning that there is mismatch between income/receipt credited to P & L account considered under other heads of income and income from heads of income from other than business income. 10. Please reconcile the same with complete details and further noticed that as per AIR Data, you have made cash deposits of Rs. 2,79,70,400/- with Corporation Bank and as per CIB information you have made cash deposits of Rs. 19,75,800/- with HDFC Bank aggregating to Rs. 2,99,46,200/-. Please explain the source of the same is supporting evidence. 11. In response to said notice, assesse furnished his reply ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the tune of Rs. 1,27,38,451/- under the head Office expenses, Tea~& coffee, conveyance, Jiya Patel, Rajlabdhi Infra Pvt.Ltd., Advance again property -Badal Shah, etc. Please explain the reason for the same. Vide letter dtd. 12th September, 2016, you had been asked to explain their source of Bank deposits. Further, you had been asked to state that if the same is from cash sales, please furnish monthwise cash sales and monthwise cash deposits. Since you are a Chartered Accountant, please state your monthly income by cash and monthly cash deposits. 4. As per information from Security Transaction Tax Return (STT Return), you have done transactions worth Rs. 12,71,23,487/-. Though you had been asked to explain the source of the same with supporting evidence and furnish a trading account and also state monthwise purchase and sales and monthwiwse income and expenditure, you have sought for adjournment. Thereafter, another opportunity of being heard was afforded to you vide this office letter dtd. 11.11.2016. In response thereto, vide letter dtd. 18.11.2016 you have contended that your broker has sent client financial account showily NIL transaction and hence asked for furnishing the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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